Introduction: In Whiten v. Pilot Insurance Co., the Supreme Court of Canada considered whether a jury award of $1 million in punitive damages against an insurance company for breach of a contract was reviewable. Also considered was whether breach of an insurer's duty to act in good faith amounted to the independent actionable wrong which is requisite to found punitive damages for breach of contract under the principle ostensibly established by the Supreme Court in Vorvis v. Insurance Corporation of British Columbia.